At many small and mid-sized defense contractors, the Facility Security Officer (FSO) can also be the contracts manager, the HR director, or the program lead.
That reality does not change what the National Industrial Security Program Operating Manual (NISPOM) requires. It only changes how hard it is to meet those requirements consistently.
Part-time FSOs face the same compliance obligations as their full-time counterparts, including:
The stakes are high. A missed requirement, an expired document, or a failed DCSA Security Review can put your FCL and your contracts at risk.
Dig deeper below to learn more.
The number of cleared contractors has grown steadily, but most growth has come from small businesses, many of which cannot justify a dedicated, full-time FSO.
At the same time, NISPOM obligations have become more demanding, not less:
The part-time FSO model was never designed for this environment. Stretching a collateral-duty FSO across these expanding obligations creates risk, not just for compliance, but for the business.
NISPOM, formalized as 32 Code of Federal Regulations (CFR) Part 117 “The Rule”, establishes the framework for protecting classified information in contractor facilities. FSOs are responsible for implementing that framework, regardless of whether the role is full-time or collateral.
Core FSO responsibilities include:
For a full-time FSO, this is a workload. For someone carrying a second or third role, it can be overwhelming.
The most common compliance gaps are not the result of negligence. They are the predictable outcome of a model that asks too much of one person.
The most frequent issues include:
We have written extensively on how FSO responsibilities now intersect with CMMC. The FSO's Guide to CMMC Readiness is a practical starting point for FSOs navigating both frameworks.
DCSA conducts Security Reviews on a risk-based cycle, but every cleared facility should be prepared for one at any time. The SRRP process evaluates your facility across multiple security areas, and findings directly affect your rating.
Reviewers will look at whether:
A poor review outcome can result in a corrective action plan, a degraded facility rating, or in serious cases, suspension of the FCL. For a contractor dependent on cleared work, those outcomes are business risks, not just compliance findings.
Also, take our 2-minute Industrial Security Readiness Quiz to quickly gauge where gaps may exist before DCSA arrives.
The Department of Defense (DoD) (also known as the Department of War) has made CMMC a contract eligibility requirement for work involving CUI. That has direct implications for FSOs, even when cybersecurity is technically managed by IT.
FSOs are responsible for areas that connect directly to CMMC compliance:
Part-time FSOs who are not looped into the organization's CMMC program can create gaps that affect both assessment outcomes and contract eligibility.
For a deeper look at how CMMC functions as a business risk, not just a technical one, see: CMMC Is Not a Cyber Problem. It's a Business Risk Issue.
Contractors operating with a collateral-duty FSO have several options for closing the gap between what is required and what one person can realistically manage.
Outsourced or supplemental FSO support provides dedicated expertise without the cost of a full-time hire. A qualified FSO support partner can:
If the part-time FSO model is the right fit for your organization, investing in proper training and structured documentation processes reduces the risk of gaps. FSO training resources from DCSA, the National Classification Management Society (NCMS), and accredited providers help collateral-duty FSOs build baseline competency.
Documentation discipline matters as much as training. A well-maintained file structure and recurring calendar of FSO obligations goes a long way toward SRRP readiness.
For contractors whose cleared workload is growing, a dedicated FSO may be the right long-term answer. The question is how to manage compliance in the gap between where you are now and where you are headed.
Our FSO and Clearance Services team works directly with defense contractors who need expert support without adding headcount. Our team provides:
The goal is not to replace your team. It is to make sure your FSO function is covered at the level DCSA and your contracts require, regardless of how many hats your internal team is wearing.
It depends on the scope of your cleared program. For facilities with a small number of cleared employees and limited program activity, a well-organized collateral-duty FSO can manage the workload. As the program grows, the risk of gaps increases significantly. Structured support from an experienced FSO partner is often a cost-effective way to maintain compliance without a full-time hire.
DCSA will typically issue findings and require a corrective action plan. Depending on severity, your facility rating may be affected. In cases of serious or repeated deficiencies, DCSA can suspend or revoke the FCL, which directly impacts your ability to hold and perform on cleared contracts.
CMMC does not replace NISPOM, but it adds an overlapping layer of requirements that FSOs need to understand. Physical protection, CUI handling, and access control areas that FSOs typically manage are also assessed under CMMC Level 2. FSOs who are not aligned to their organization's CMMC program can inadvertently create compliance gaps in both areas.
When your collateral-duty FSO is consistently unable to complete required activities on time, when your cleared program is growing faster than your internal capacity, when you are approaching a DCSA review with documentation gaps, or when you are simultaneously navigating CMMC compliance, these are all signals that supplemental support is worth evaluating.